ML20138J381
| ML20138J381 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/01/1985 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| OL-A-068, OL-A-68, NUDOCS 8510290326 | |
| Download: ML20138J381 (22) | |
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- 2. s ui i May 25, 1984 ST-HL-AE-1095 File No.: pG2.4/84.1 Mr. John T. Collins Regional Administrator, Region IV Nuclear Regulatory Comission 611 Ryan Plaza Dr., Suite 1000 Arlington, Texas 76012
Dear Mr. Collins:
South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Programatic Audit of Backfill Activities In response to the generic implications discussed in our response to Notice of Violation 83-24, Houston Lighting & Power Company (HL&P) has performed a technical / quality audit of backfill related activities.
This audit was completed on April 3,1984, and covered FSAR comitments, specifications, and procedures associated with Category I backfill. The organizations involved with Category I backfill: Bechtel, Ebasco, and Pittsburgh Testing Laboratory (PTL) were included in this audit. The purpose of this letter is to provide the NRC with a sumary of the audit f ndings and to delineate actions that have been taken as a result of these findings.
The audit resulted in a number of findings against the above three organizations. A sumdry listing of each finding and the resulting corrective action and specific recurrence control, if any, is provided in Attachment 1.
HL&P and Bechtel Engineering have reviewed the reported conditions and determined that no substantive degradation of the ongoing and/or past backfill work has occurred and that from a technical standpoint the integrity of the backfill was not affected.
In adoition, the audit findings were evaluated against the reportability criteria of 10CFR50.55(e). These evaluations concluded that none of the itemlui9InstjMf@,ya ymtt,able deficiency.
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COPY Houston Lighting & Power Company-ST-HL-AE-1095 File No.: G2.4/84.1 Page 2 Subsequent to the audit, all Category I backfill operations were temporarily suspended to allow for the orderly definition and implementation of the corrective actions assigned to each of the organizations involved. Presently, the findings have been resolved and construction activities related to Category I backfill operations are proceeding.
If you have any questions regarding this matter, please contact Mr. Michael E. Powell at (713) 993-1328.
Very truly yours, G. W pr Executiv ce President SMH/ mpg
Attachment:
Backfill Audit Summary 4
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Houston 1.ighting & Power Company Page 3 CC*
Darrell G. Eisenhut, Director Brian E. Berwick, Esquire Division of Licensing Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Regulatory Comission P. O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Victor Nerses, Project Manager Lanny Sinkin U.S. Nuclear Regulatory Comission Citizens Concerned About Nuclear Power 7920 Norfolk Avenue 114 W. 7th, Suite 220 Bethesda, MD 20016 Austin, TX 78701 D. P. Tomlinson Robert G. Perlis, Esquire Resident Inspector / South Texas Project Hearing Attorney c/o U.S. Nuclear Regulatory Comission Office of the Executive Legal Director P. O. Box 910 U.S. Nuclear Regulatory Comission Bay City, TX 77414 Washington, DC 20555 M. D. Schwarz, Jr., Esquire Charles Bechhoefer, Esquire Baker & Botts Chairman, Atomic Safety & Licensing Board One Shell Plaza U.S. Nuclear Regulatory, Comission Houston, TX 77002 Washington, DC 20555 '
J. R. Newman, Esquire Dr. James C. Lamb, III Newman A Holtzinger, P.C.
313 Woodhaven Road 1025 Connecticut Avenue, N.W.
Chapel Hill, NC 27514 Washington, DC 20036 Judge Ernest E. Hill Director, Office of Inspection Hill Associates and Enforcement 210 Montego Drive U.S. Nuclear Regulatory Comission Danville, CA 94526 Washington, DC 20555 E. R. Brooks /R. L. Range William S. Jordan, III, Esquire Central Power & Light Company Harmon & Weiss P. O. Box 2121 1725 I Street, N.W.
Corpus Christi, TX 78403 Suite 506 Washington, DC 20006 H. L. Peterson/G. Pokorny City of Austin Citizens for Equitable Utilities, Inc.
P. O. Box 1088 c/o Ms. Peggy Buchorn Austin, TX 78767 Route 1, Box 1684 Brazoria, TX 77422 J. B. Poston/A. vonRosenberg City Public Service Board P. O. Box 1771 San Antonio, TX 78296 Revised 04/03/84
COPY ST-HL-AE-1095 Attachment Page 1 of 18 CATEGORY 1 BACKFILL AUDIT FINDING
SUMMARY
(May,1984)
GENERAL Three broad categories of findings were identified during the audits, specifically:
o Certain FSAR commitments were not translated literally into the proiect specifications.
o Non-adherence by personnel to approved procedures.
o Soil testing practices which deviated from strict compliance with the prescribed ASTM standards.
To prevent recurrence of problems of the type discovered during this audit, the following actions are being implemented:
o Bechtel Engineering is reviewing FSAR and Show Cause commitments related to backfill, welding, and concrete to ensure that such comitments are completely reflected in the appropriate project specifications, Any specification changes that are required will be implemented immediately.
o Ebasco Quality Control (QC) and PTL personnel have been instructed by their respective management to strictly adhere to established project specifications and procedures as part of the resolution to specific findings identified during the audit.
o Bechtel Engineering has reemphasized to Ebasco and PTL management the need for strict adherence to project specifications, procedures, and ASTM standards.
o A special investigative surveillance of backfill operations was performed by Bechtel Quality Assurance (QA) personnel and geotechnical personnel assigned to PTL facilities. The results are being evaluated by Bechtel engineering for any additional recurrence control requirements.
o Additional effectiveness inspections /surveillances are being conducted by Bechtel QC above and beyond those surveillances conducted by Bechtel QA.
SPECIFIC FINDINGS
- 1) Finding Specification 2YO50YS044, " Field and Laboratory Testing of Earthwork Construction", invokes ANSI N45.2.6-1973 only and does not commit conformance to Regulatory Guide 1,58 (Rev. O, 08/73) as modified by positions C.5, C.6, C.7, C.8, and C.10 of Revision 1.
(Quality Assurance Program Description, Part A requirement).
Corrective Action This specification will be updated to reflect this regulatory requirement.
W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page 2 of 18 Corrective Action to Preclude Recurrence This specification and other specifications utilized by contractbr personnel will be reviewed to insure that the appropriate regulatory requirements of Regulatory Guide 1.58 are included in the specifications. Site contractor personnel have been evaluated, and verified to be qualified per this commitment.
- 2) Finding No objective evidence was provided to show what changes were made to specifications and procedures as a result of HL&P's commitment VA(2)M9 in response to NRC's Order to Show Cause dated April 30, 1980.
In VA(2)M9 HL&P committed to document locations and sequence of backfill placements and in-place density tests.
Corrective Action A review by HL&P indicates that this commitment applied to backfill placed i
prior to August 1, 1980 and is, therefore, closed.
Corrective action is not i
necessary.
Corrective Action to Preclude Recurrence A comprehensive program has been implemented to ensure that FSAR and Show Cause commitments related to welding, concrete, and backfill are reflected i
j in project specifications.
- 3) Finding No objective evidence was provided to show what documentation has been generated by Ebasco and PTL to ensure compliance to Show Cause Item VA(2)M9.
See Finding #2.
Corrective Action See Finding #2.
Corrective Action to Preclude Recurrence See Finding #2.
- 4) Finding l
Specification 3YO69YS0043 states in part, "the frequency of testing may be changed as approved by the Construction Manager". The method of notifying PTL in the past was by letter, e.g., letter ST-YS-0Q-00182 dated February 2, 1983 which modified testing frequency.
This manner of notification is not appropriate for conveying information of this nature.
Corrective Action The referenced letter has been rescinded.
W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page 3 of 18 Corrective Action to Prevent Recurrence Bechtel Engineering personnel have been instructed by memorandum dated February 27, 1984 as a result of the Notice of Violation in Inspection Report 83-24, of the importance of reviewing related correspondence to assure that when technical changes are made those changes are contained in the appropriate design disclosure documents.
5)
Finding Specification 3YO69YS0043 does not require at least one relative density sample per shift to be obtained from the compacted backfill. This is a FSAR requirement.
Corrective Action A specification change notice has been issued which requires at least one relative density test per work shift.
Corrective Action to Preclude Recurrence See Finding #2.
- 6) Finding Specification 3YO69YS0043 recuires tests to be performed a minimum of once per eight hour work day. The FSAR requires this frequency of test be once per work shift.
l l
Corrective Action A specification change notice has been issued to bring the specification in conformance with the FSAR.
Specifically, the "8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" time frame has been substituted with " work shift".
Corrective Action to Preclude Recurrence See Finding #2.
- 7) Finding Specification 3YO69YS0043 does not contain the FSAR coninitment to obtain a minimum of three in-place density tests within each tested subgrade area.
Corrective Action FSAR Section 2.5.4.5.6.2.5 has been amended (Amendment #38) to delete the requirement of doing "three additional density tests within each tested a rea. " Subgrade preparation is performed in order to obtain a suitable surface for placement of structural backfill.
Subgrade preparation is not a geotechnical design item as the adequacy of the ir.-situ soil is determined by foundation verification (see FSAR Section 2.5.4.5.5.2).
Normal practice is to obtain one density test within each tested area (typically 10,000 sq.
ft. or greater), which, together with foundation verification, is sufficient to ensure the adequacy of subgrade soil.
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COPY ST-HL-AE-1095 Attachment Page 4 of 18 Corrective Action to Preclude Recurrence See Finding #2.
- 8) _ Finding PTL has been allowed to take exception to the hydrometer portion of ASTM 0422 for Category I Structural Backfill, but the FSAR and Specifications 2YO60YSO44 and 3YO69YS0043 do not make this exception.
Corrective Action Hydrometer analysis for structural backfill is not considered essential Determination of distribution of grain sizes below v200 mesh is not require per project specifications.
particles below this size range. Hydrometer analysis is only necessary for Amendment 38 to the FSAR notes this exception to ASTM 0422.
to allow exception to this requirement. Specification Change Notices have also
)
Corrective Action to Preclude Recurrence See Finding #2.
- 9) Finding The FSAR requires two bulk density determinations for each new bag of sand used for sand cone tests.
procedures do not incorporate this requirement.The Specifications and PTL im Corrective Action Tests show that there is very little deviation in density results, described in FSAR paragraphtherefore, testing in excess of the requ 2.5.4.5.6.2.5 FSAR Amendment 38 includes a deletion of this clarification.is technically not reflects a commitment to the specific testing requirements of ASTM 01556.
The FSAR now Corrective Action to Preclude Recurrence See Finding #2.
- 10) Finding The FSAR requires bulk density sand to have 100% passing the No. 10 sieve i
and none passing the No. 200 sieve.
ASTM 01556, which is not incorporated into the Specifications or PTLT implementing procedures.
Corrective Action FSAR Amendment 38 deletes this requirement which is in excess of the ASTM standard requirement.
determine the acceptability of bulk density sand.The testing specified in I
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COPY ST-HL-AE-1095 Attachment Page 5 of 18 Corrective Action to Prevent Recurrence See Finding #2.
- 11) Finding Specification 3YO69YS0043 does not contain the FSAR conunitment to obtain backfill stockpile for each 20,000 cubic yards delivered. sam Corrective Action A relative density test (ASTM D2049) by itself (i.e., without an accom-panying field density test) provides no information about the quality of the material in the stockpile and cannot be considered an acceptance criteria.
FSAR Amendment 38 includes a deletion of the ASTM D2049 test for stock quality control.
Corrective Action to Preclude Recurrence See Finding #2.
- 12) Finding The Receiving Inspection procedure, WPP describe the process, methodology, spec /QCI-4.0, Revision 5 does not ific document requirements, and the approval / release process employed when Category I backfill material is received on-site as Quality Class 9 and subsequently upgraded to Qua Class 3.
Corrective Action A specific Receiving Inspection Plan (RIP) for receipt of Category I structural fill and backfill is in effect to describe the process, methodology, specific document requirements, and method of approval and release for use.
The specific RIP will be completed and enclosed in each receipt documentation package for Category I fill and backfill materials.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 13) Finding Personnel other than those assigned by the Receiving Supervisor are performing receiving functions for incoming Category I backfill material.
Corrective Action by the Material Storage Supervisor,WPP/QCI 4.0 has been revised to t
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COPY ST-HL-AE-1095 Attachment
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Page 6 of 18 i
Corrective Action to Preclude Recurrence i
The above corrective action is sufficient to preclude recurrened.
j
- 14) Finding j
" Hold for Receiving Inspection" tags are not applied to incoming Category I backfill stockpiles up to the point of QC acceptance.
Corrective Action WPP QCI-4.0 has been revised to reflect special requirements for application of hold tags on incoming Category 1 stockpiles.
s Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
4 4
- 15) Finding Receiving QC personnel have been stamping the " Accept" column of the Receiving Inspection Report (RIR) which requires a visual inspection for cleanliness of incoming Category I backfill material, even though these personnel have not performed the required visual inspection.
Corrective Action Acceptance of backfill material is based on acceptable sieve results, not by visual inspection as indicated on the RIP's.
The RIP form has been clarified to state this intent.
I Corrective Action to Preclude Recurrence
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The above corrective action is sufficient to preclude recurrence.
j
- 16) Finding i
The cognizant Supplier Quality Representative of Field Procurement is not j
signing and dating MRR's for incoming Category I backfill material as j
required per WPP/QCI-4.0.
l Corrective Action Training has been implemented to ensure that appropriate actions concerning MRRs are undertaken.
Corrective Action to Preclude Recurrence i
j The above corrective action is sufficient to preclude recurrence. WPP/QCI-4 l
has been revised to add special requirements for receiving of structural i
backfill.
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COPY ST-HL-AE-1095 Attachment Page 7 of 18
- 17) Finding Bechtel QC has not performed an Effectiveness Inspection of Category I backfill activities since October,1982, a period of approximately 16 months.
Corrective Action Starting April 9,1984, the Bechtel QC Civil Discipline is working on an accelerated schedule with a goal of one Effectiveness Inspection /
Surveillance per day. This program is structured to provide a much greater probability of addressing each activity at least once a month.
The flexibility to increase the frequency for problem areas will still exist.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
activities for approximately five (5) months.
Corrective Action See Finding #17.
Corrective Action to Preclude Recurrence See Finding #17.
- 19) Finding No objective evidence was provided to show approval by the Construction Manager of compaction control criteria developed by PTL to be utilized as i
required by Specification 2YO60YS044.
Corrective Action The cited specification implies that the compaction control criteria is developed by the testing contractor.
In reality the compaction control criteria, depending on the type of backfill, is clearly stated ir. Specifica-tion 3YO69YS0043.
The lab involvement is limited strictly to performing the required tests.
Interpretation of test data is not in the testing contractor's scope of work. A specification change notice has been issued against Specification 2YO60YSO44 to clearly state the above concept.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page 8 of 18
- 20) Finding No evidence was provided to show that compaction control criterfa was submitted prior to use as required by Form G-321-E of Specification 2Y060YSO44.
Corrective Action Inclusion of " Compaction Control Criteria" on form G-321-E was inappropriate.
this requirement.A specification change notice has been issued eliminating Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
- 21) Finding A Receiving Inspection Report (RIR) listed the wrong Material Receiving Report (MRR) number.
Corrective Action l
Affected Receiving Inspection Report was corrected in accordance with WPP/QCI 6.0.
_ Corrective Action to Prevent Recurrence No corrective action to prevent recurrence is required.
- 22) _ Finding Testing frequencies are not directed by both the Constructor and the Construction Manager as required by Specification 2YO60YSO44.
Corrective Action Specification 2YO60YSO44 has been revised to indicate that all testing frequencies are contained in Specification 3YO69YS0043.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
- 23) Finding The Soils Inspection Procedure does not provide criteria on density variation with depth to enable QC to determine the correct location for testing as required by Specification 3YO69YS0043 and the FSAR.
the field test elevation selection process does not give representativeTherefore, 3
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density information for all depth intervals within the lift.
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COPY ST-HL-AE-1095 Attachment Page 9 of 18 Corrective Action QCP-10.10 has been revised to require that all testing elevations,be recorded and maintained on the Field Density / Relative Density Log and given to the testing laboratory for recording on test reports. FSAR has been revised in Amendment 38 to indicate that tests are selected such that they give representative density information for all lifts within the fill.
Specifications and procedures have been modified per the FSAR clarification.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence. Also, see Finding #2.
- 24) Finding The Soils Inspection Procedure does not require test depths to be recorded and thus no evidence, in general, can be provided to demonstrate backfill installed by Ebasco has been tested at the required depth. Specifically, no evidence exists to demonstrate tests below the 30-inch diameter ECW pipes are taken at a depth of 7 inches below the invert. Additionally, test depth information has not been provided by PTL.
Corrective Action See Finding #23.
Corrective Action to Prevent Recurrence See Finding #23.
- 25) Finding The average minimum / maximum values obtained during the Relative Density determination were not applied in accordance with Specification 3YO69YS0043.
Corrective Action Specification has been revised to clarify intent of criteria for averaging Min-Max density test. Procedures have been revised to reflect this change.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
- 26) Finding Backfill lifts are not tested prior to placing new material (i.e., the nextlift). This is not in accordance with QCP-10.10.
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COPY ST-HL-AE-1095 Attachment Page 10 of 18 Corrective Action t
QCP-10.10 has been revised to reference Backfill Testing Specification 3YO69YS0043 which does not prohibit testing of lifts after placement of one additional lift.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 27) Finding Quality Control has not obtained the Bechtel Foundation Verification Engineer's signature on backfill inspection reports to provide evidence that Bechtel has performed geologic mapping and accepted natural subgrade when encountered during the construction of safety-related duct banks and manholes.
Corrective Action Foundation verification (including geological mapping) is not considered essential for auctbanks and manholes as these structures are very lightly loaded. A Specification Change Notice was issued to clarify this requirement.
The FSAR has been updated in Amendment 38 to reflect that no geologic mapping is required for duct banks and manholes. Procedures have been revised to reflect this change.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence. Also see Finding #2.
- 28) Finding Compaction for local excavations for density testing within the fill was not performed as it was for the original placement.
Corrective Action Responsible supervisors have been instructed that regardless of the apparently insignificant size of excavations the backfill must be performed according to the procedure and specification.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
1
- 29) Finding i
Quality Control was not notified by construction personnel that local excavations for density tests within the fill had been backfilled, compacted, and were ready for inspection.
i W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page 11 of 18 Corrective Action Construction supervisors have been instructed to make the QC Inspector aware that local excavations are being backfilled.
Testing will not be required since this was not and is not the intent of the specification.
Construction procedures have been revised to reflect these requirements.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 30) Finding The Soils Inspection procedure does not require verification / inspection to insure the gradation and distribution of materials in the compacted areas is such that the backfill or fill is not segregated. This item is required by Bechtel Specification 3YO69YS0043.
Corrective Action The affected procedure (QCP-10.10) has been updated to reflect this requirement.
Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.
- 31) Finding The Soils Procedure does not require verification / inspection to insure fill surfaces are constructed so water will readily drain off at all times as required per Specification 3YO69YS0043.
Corrective Action See Finding #30.
Corrective Action to Prevent Recurrence See Finding #30.
- 32) Finding The Soils Inspection Procedure does not require verification / inspection to insure compaction is not allowed within 300 feet of an area where in-situ density tests are being performed.
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ST-HL-AE-1095 Attachment Page 12 of'18 4
Corrective Action i
i See Finding #30.
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Corrective Action to Prevent Recurrence See Finding #30.
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- 33) Finding 1-The Soils Inspection Procedure does not require verification / inspection to insure that concrete mats and basement walls have been waterproofed, and 1
that backfilling is performed so that the protective waterproofing material j
is not damaged.
}
Corrective Action Waterproofing is not a safety-related installation.
Construction procedures and nonsafety-related inspection procedures have been updated to reflect the above requirement.
4 l
Corrective Action to Prevent Recurrence i
l No corrective action is required to preclude recurrence.
- 34) Finding i
l The Soils Inspection Procedure does not require verification / inspection to insure backfill adjacent to structures or over portions of foundations is i
placed and compacted symetrically and uniformly in a manner to prevent eccentric loading or unbalanced pressure upon or against the structures as required by Specification 3YO69YS0043.
Corrective Action i
See Finding #30.
i Corrective Action to Prevent Recurrence See Finding #30.
- 35) Finding 1
Section 10.3 of the HL&P Project Quality Assurance Program (PQAP) requires j
that the inspection procedures shall provide for recording the results of I
inspection operations.
However, verifications performed during the i
qualification program for Wacker vibratory plate compactors are not i
procedurally required to be recorded on appropriate forms.
i l
Corrective Action QCP-10.10 has been revised to require the documentation of inspections.
1 i
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COPY ST-HL-AE-1095 Attachment Page 13 of 18 Corrective Action to Prevent Recurrence The above corrective action is sufficient to preclude recurrence.,
- 36) Finding Verifications perfonned during the Test Fill for Qualification of Various Hand Operated Compactors are not procedurally required to be recorded.
Corrective Action See Finding #35.
Corrective Action to Prevent Recurrence See Finding #35,
- 37) Finding No letter of approval from Bechtel Engineering for the results of the test i
fill program for hand propelled vibratcry plate compactors was contained in the document package.
Corrective Action This item was corrected during the audit.
Corrective Action to Preclude Recurrence No corrective action to preclude recurrence is required.
- 38) Finding Category I backfill samples are not prepared for testing as described in ASTM D421.
Corrective Action Specifically, samples are oven dried instead of air dried and are not separated on a No.10 sieve or subsequently washed. A Supplier Document Deviation Request (SDDR) has been approved by Bechtel allowing the methods utilized. Discussions were conducted with ASTM on April 26, 1984 to verify that the use of oven drying met the intent of the standard for perfonning sieve analyses on granular material. This was so confirmed. Specification 2YO60YSO44 is currently in revision to reflect exceptions taken to the ASTM testing procedures.
Corrective Action to Preclude Recurrence The absolute need for strict adherence to the specified ASTM standards (unless deviation is authorized by Bcchtel) has been reiterated to PTL. PTL soil testing activities have been under additional surveillance by Bechtel QA personnel and geotechnical engineering assigned to PTL facilities.
Additional effectiveness inspections /surveillances are being conducted by Bechtel QC above and beyond those surveillances conducted by Bechtel QA.
W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page IC i 18 l
- 39) Finding The length of mechanical sieving time and the thoroughness of sieving, as required by ASTM 0422, has not been determined or documented.
Corrective Action A Field Change Request has been issued which revises PTL form ST-8 to include a line for documenting the time in shaker.
Thoroughness is verified by shaking for a minimum of eight (8) minutes as demonstrated by comparison test.
Corrective Action to Preclude Recurrence See Finding #38.
- 40) Finding Category I backfill samples passing the No. 10 sieve are not washed over a No. 200 sieve as required by ASTM 0422.
Corrective Action A SDDR has been approved to delete this requirement. The deletion of this requirement is technically justified since actual backfill material contains only about I to 2% fines. The specification allows fines up to 7%. Washing would not substantially increase the amount of fines which could ultimately pass a No. 200 sieve as demonstrated by comparison tert.
Corrective Action to Preclude Recurrence See Finding #38.
411 Finding The hardness of Category I backfill material is not recorded as required by ASTM 0422.
Corrective Action The appropriate form has been changed to require the determination of the hardness of the material.
Corrective Action to Preclude Recurrence See Finding #38.
- 42) Finding Bulk density determinations for density sand utilized in sand-cone tests are not performed in strict compliance with the procedure described in ASTM D1556.
W2/LIC/a
COPY ST-HL-AE-1095 Attachment Page 15 of 18 Corrective Action An SODR has been approved allowing testing to be performed by an' alternate and equivalent method stated in the latest revision of ASTM 01556.
Corrective Action to Preclude Recurrence See Finding Response #38.
- 43) Finding The calibration of the mold utilized in the Relative Density determination is not accomplished in strict compliance with the procedure described in ASTM D2049. Volume was not determined by measurement of the mold and compared with water volume results.
Corrective Action 1
Field Change Request has been approved allowed testing to be performed per i
the requirements of the superseding revision to ASTM 02049 (ASTM 04253-83 and D4254-83), i.e., the volume will be determined by the water volume method only.
Corrective Action to Preclude Recurrence See Finding #38.
- 44) Finding Initial dial gage readings obtained during the maximum portion of the Relative Density test are not obtained as described in ASTM 02049.
Corrective Action Field Change Request has been approved which revised Form CAL-22 to follow the ASTM Standard explicitly.
Corrective Action to Preclude Recurrence See Finding #38.
- 45) Finding
" Match Marks" are not utilized when dial gage measurements are made during the maximum density portion of the Relative Density tests as required by ASTM 02049.
i Corrective Action The match marks have been applied to the testing mold.
Corrective Action to Preclude Recurrence l
See Finding #38.
W2/LIC/a
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COPY ST-HL-AE-1095 Attachment Page 16 of 18
- 46) Finding i
Sample material is not placed in the mold for Relative Density determina-tions in strict compliance with the requirements of ASTH D2049. Technicians were adding material by hand to the surface of the moid, after screening.
Corrective Action Technicians have been directed that no material shall be added after striking off.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence. Also see Finding #38.
- 47) Finding No written procedure or instructions (by PTL) exist for sampling backfill material from the stockpiles.
Corrective Action A Field Change Request has been approved to include an instruction 3heet for sampling from stockpiles.
4 Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 48) Finding The procedure used for determining the bulk density of sand utilized in sand cone tests does not adequately describe how the sand from different bags is thoroughly blended to insure zones of different bulk density do not result within the container.
Corrective Action A Field Change Request has been approved which revises Instruction Sheet IS-CAL-19 which changes the calibration frequency to every bag.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude the recurrence.
- 49) Finding The method used (scoop or funnel) for determining the minimum density portion of the Relative Density tests is not recorded on Form ST-6.
W2/LIC/a
COPY ST-HL-AE-1095 i
Attachment Page 17 of 18 Corrective Action The required form has been revised to include check boxes for melhed used, e.g., scoop or funnel.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 50) Finding Retests reference the original test number but not the original report number and the retests are not filed with the original report as required by PTL Procedure QC-DC-1, Revision 11.
Corrective Action PTL files are being updated to insure that all retests are filed with the original test report.
Retest will be assigned an appropriate document number to facilitate tracking.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 51) Finding Test procedure instruction sheet 15-510-5049-69 references a superceded procedure for relative density table calibration rather than the current procedure in use.
Corrective Action A Field Change Request has been approved revising the above instruction sheet to reference the current procedure.
Corrective Action to Preclude Recurrence The above corrective action is sufficient to preclude recurrence.
- 52) Finding Backfill samples were being temporarily retained without appropriate status indicator tags.
Corrective Action Corrected during the audit.
Corrective Action to Preclude Recurrence No corrective action to prevent recurrence is required.
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- 53) Finding A Relative Density table calibration was documented on a superceded form.
Corrective Action i
Corrected during the audit.
No further action required, i
Corrective Action to Preclude Recurrence No corrective action to prevent recurrence is required.
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